Richard Jeens (Slaughter and May) gives an overview of the significant changes in the rules governing tax disputes in the last year or two and considers where this leaves taxpayers now, whether as part of active disputes, an M&A transaction or day to day business.
HMRC’s chief executive, Lin Homer, announced last week in a Treasury Select Committee hearing that the French authorities have formally agreed that HMRC can share stolen HSBC Suisse customer account data with other law enforcement agencies and regulators, for the purposes of pursuing criminal off
Anti-avoidance legislation having immediate effect from 26 February 2015 will restrict to nil the expenditure qualifying for plant and machinery allowances in a sale and leaseback or connected-party transaction, where the person disposing of the asset, or a person connected with them, acquired it
Criticism of HMRC’s failure to prosecute HSBC Swiss tax evaders has been quite unfair, writes Jonathan Fisher QC (Devereux Chambers). There are problems with criminal prosecution and the decision to focus on tax collection through civil settlement is the right one. It makes little sense to criminally prosecute these cases.
The penalty for late self-assessment filing needs rethinking. HMRC's recent discussion document looks promising, writes Paul Aplin.
Following the allegations and outcry in recent weeks over tax evasion involving HSBC’s Swiss bank accounts and criticism of HMRC’s activities when the information was handed to them in 2010, shadow chancellor Ed Balls tabled an urgent question on tax avoidance and HSBC in the House of Commons on
The substantial shareholdings exemption is in danger of being misunderstood, warns Heather Self (Pinsent Masons)
Andrew Goldstone and Charlie Sosna (Mishcon de Reya) round up the latest private client news, including: the remittance basis charge consultation; a report on tax incentives for art; Hutchings; and BiGDUG Limited Remuneration Trust (from Guernsey)
HMRC has announced that the Court of Appeal has ruled in its favour against Eclipse Film Partners (No 35) LLP, which it said ‘protected an estimated £635m in tax’.
Following the censure HMRC received over the HSBC ‘Swiss leaks’ before the Public Accounts Committee on 11 February, as well as further press criticism, HMRC issued a statement on when and how it came by the leaked HSBC Suis